This is an English translation of the Política de Privacidad, updated to include Google Ads measurement. In case of any discrepancy, the Spanish version prevails.
At Spanish Sin Fronteras we take the protection of your personal data very seriously. This Privacy Policy explains what data we collect, what we use it for, who we share it with and what rights you have, in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on Personal Data Protection and the Guarantee of Digital Rights (LOPDGDD).
1. Data controller
- Controller: Carlos Oller Berbel
- Tax ID (NIF): 76635801P
- Address: Calle Pi y Margall, 19, 04630 Garrucha, Almería, Spain
- Email: hola@spanishsinfronteras.com
- Phone: +34 641 67 98 59
Given the volume and nature of the data processed, no Data Protection Officer has been appointed. For any question about your personal data, you can contact us directly at the email address above.
2. What data do we collect and where from?
We collect the following data, which you provide yourself through the Site:
2.1 Contact form
- Name
- Email address
- Phone number (optional)
- Content of your message
2.2 Free trial class form
- Full name
- Email address
- Phone / WhatsApp number
- Current level of Spanish (self-assessment, optional)
- When you would like to start (optional)
- Learning goals and availability, if you share them with us
2.3 Level test (Speaking Check)
- Full name
- Email address
- Phone / WhatsApp number
- Answers to the grammar test
- Audio recordings (if you choose to provide them)
- Preferred lesson times
2.4 Purchase of packs / subscriptions
- Full name
- Postal address and country of residence
- Email address
- Phone number
- Billing details (including tax ID where applicable)
- Payment details: we do not store card details on our systems; they are collected and processed directly by Stripe in its secure environment (see section 5)
- Purchase history and active subscriptions
2.5 Browsing data
- IP address
- Browser and device type
- Pages visited and time spent on them
- Information obtained through cookies (see the Cookie Policy)
- If you arrive from an ad, the campaign details and the advertising click identifier (for example Google’s “gclid”), which we store with your enquiry to know which ad brought you
3. Why do we process your data, and on what legal basis?
| Purpose | Legal basis | Retention period |
|---|---|---|
| Answering your enquiries and messages | Consent (Art. 6.1.a GDPR) | For the duration of the enquiry + 1 year |
| Booking and managing the free trial class | Pre-contractual measures (Art. 6.1.b GDPR) | 1 year if you do not become a student |
| Assessing your level of Spanish | Consent (Art. 6.1.a GDPR) | 1 year if you do not become a student |
| Managing the contract, giving the classes and processing recurring payments | Performance of a contract (Art. 6.1.b GDPR) | For the duration of the contractual relationship |
| Issuing invoices and complying with tax and accounting obligations | Legal obligation (Art. 6.1.c GDPR) | 6 years (Art. 30 Spanish Commercial Code) |
| Sending commercial communications about our services | Consent (Art. 6.1.a GDPR) or legitimate interest for existing customers | Until you withdraw your consent |
| Analysing the use of the Site to improve it | Consent (Art. 6.1.a GDPR) | As indicated in the Cookie Policy |
| Measuring the results of our online advertising (Google Ads) and, where you allow it, showing you our ads again | Consent (Art. 6.1.a GDPR) where required; legitimate interest outside the EEA, the UK and Switzerland | As indicated in the Cookie Policy; data shared for conversion measurement is used by Google only for that purpose |
Automated decisions: we do not carry out profiling or take automated decisions with legal effects on Users.
4. Do you have to provide your data?
The data marked as required in each form is necessary for the stated purpose. If you do not provide it, we will not be able to provide the corresponding service (answer your enquiry, book the class, process the purchase, etc.). Data marked as optional can be left out without affecting the main service.
5. Who do we share your data with?
Your data may be disclosed to the following recipients, only for the purposes indicated:
5.1 Data processors
- SYSDOP LLC (Wyoming, United States): hosting of the website and its data (server located in the United States).
- Stripe Payments Europe Ltd. (Ireland): card payment processing and subscription management.
- Google Ireland Ltd. / Google LLC (Google Analytics): statistical analysis of website traffic.
- Google Ireland Ltd. / Google LLC (Google Ads): measuring which ads lead to enquiries and, where allowed, remarketing. When you send a form, an encrypted (hashed) version of your email address and phone number may be sent to Google so it can match the enquiry to an ad click (“enhanced conversions”). Google cannot read these values and does not use them for other purposes.
- Meta Platforms, Inc. (if the Facebook/Instagram Pixel is used): measurement of advertising campaigns.
All data processors are bound by data processing agreements in accordance with Art. 28 GDPR and guarantee an adequate level of protection.
5.2 Disclosure to public authorities
Your data may be disclosed to the Spanish Tax Agency, Social Security and other public authorities when there is a legal obligation to do so (for example, tax returns).
6. International data transfers
Some of our providers (our hosting provider, SYSDOP LLC, as well as Stripe, Google and Meta) may process your data in countries outside the European Economic Area, mainly the United States. These transfers are made under:
- Adequacy decisions of the European Commission (where they exist).
- Standard Contractual Clauses approved by the European Commission.
- Other appropriate safeguards under Chapter V of the GDPR.
You can request a copy of the applicable safeguards by writing to hola@spanishsinfronteras.com.
7. What are your rights?
You have the right to:
- Access: know what data of yours we process.
- Rectification: correct inaccurate or incomplete data.
- Erasure: ask us to delete your data when it is no longer needed.
- Restriction of processing: ask us to stop processing your data in certain cases.
- Objection: object to processing on grounds relating to your particular situation.
- Portability: receive your data in a structured format or have it transferred to another controller.
- Withdrawal of consent: at any time, without affecting the lawfulness of prior processing.
- Not to be subject to automated decisions with significant legal effects.
How to exercise your rights: email us at hola@spanishsinfronteras.com stating the right you wish to exercise and attaching a copy of your ID card or an equivalent document. We will reply within one month at the latest.
Complaints to the supervisory authority: if you believe that the processing of your data does not comply with the law, you can lodge a complaint with the Spanish Data Protection Agency (AEPD): www.aepd.es · C/ Jorge Juan, 6, 28001 Madrid, or with the data protection authority of your country.
8. Security measures
We have implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk: encrypted communications (HTTPS), restricted access to data, regular backups and the choice of providers that comply with GDPR standards.
Despite these measures, no system on the internet is 100% secure. You agree to notify us as soon as possible of any security breach you become aware of.
9. Minors
The services of the Site are intended for people over 14, the minimum legal age in Spain to consent to the processing of personal data. If you are under that age, you must have the authorisation of your parents or legal guardians before providing any data. Children under 14 must not use the Site without supervision.
10. Changes
We reserve the right to modify this Privacy Policy to adapt it to new laws, case law or changes in our practices. When substantial changes are made, we will inform you by email or through a prominent notice on the Site.
Last updated: 19 May 2026 (English version published 20 October 2026).